#Section 148A IT Act

The Karnataka High Court quashed an income tax assessment against an agricultural co-operative society for failing to afford it a hearing on its claim for exemption under Section 80P, reinforcing that procedural fairness is non-negotiable even in faceless assessments. The ruling mandates that tax authorities must entertain substantive claims under special exemptions before finalizing assessments, protecting cooperative societies from arbitrary demand notices and bank freezes.

ITAT Ahmedabad has ruled that reassessment proceedings under Section 148A are void if the Assessing Officer relies on borrowed satisfaction rather than forming an independent opinion after issuing mandatory notice. This sets a vital precedent for taxpayers: procedural compliance is non-negotiable, and mechanical reopening without reasoned application of mind violates natural justice and renders assessments legally unsustainable.